title v operating permit · 2010. 8. 9. · ng natural gas nhdes ... model vc-4 serial number 4759...

44
STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources Division TITLE V OPERATING PERMIT Permit No: TV-OP-010 Date Issued: April 11, 2007 Significant Permit Modification: November 3, 2009 This certifies that: University of New Hampshire 17 Leavitt Lane Durham, NH 03824-3522 has been granted a Title V Operating Permit for the following facility and location: University of New Hampshire Main Street Durham, NH Facility ID No: 3301700009 Application No: 04-0220, December 31, 20003 and November 9, 2005, received Title V renewal application 08-0513, November 24, 2008, received Significant Permit Modification request This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V applications above filed with the New Hampshire Department of Environmental Services under the signature of the responsible official certifying to the best of his or her knowledge that the statements and information therein are true, accurate and complete. Responsible Official: Technical Contact: Paul Chamberlin Jim Dombrosk Asst. V.P. Energy & Campus Development Director of Energy & Utilities (603) 862-4452 (603) 862-2345 This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of the Code of Federal Regulations, Title 40, Part 70. This Permit is effective upon issuance and expires on April 30, 2012. _____________________________________ Director, Air Resources Division

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Page 1: TITLE V OPERATING PERMIT · 2010. 8. 9. · NG Natural Gas NHDES ... Model VC-4 Serial Number 4759 Nat Com Burner Model DBG 582R Serial Number 9511-1 2004 66.3 MMBtu/hr Natural gas,

STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources Division

TITLE V OPERATING PERMIT Permit No: TV-OP-010

Date Issued: April 11, 2007

Significant Permit Modification: November 3, 2009

This certifies that:

University of New Hampshire

17 Leavitt Lane

Durham, NH 03824-3522

has been granted a Title V Operating Permit for the following facility and location:

University of New Hampshire

Main Street

Durham, NH

Facility ID No: 3301700009

Application No: 04-0220, December 31, 20003 and November 9, 2005, received Title V renewal application

08-0513, November 24, 2008, received Significant Permit Modification request

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V

applications above filed with the New Hampshire Department of Environmental Services under the signature of

the responsible official certifying to the best of his or her knowledge that the statements and information therein

are true, accurate and complete.

Responsible Official: Technical Contact:

Paul Chamberlin Jim Dombrosk

Asst. V.P. Energy & Campus Development Director of Energy & Utilities

(603) 862-4452 (603) 862-2345

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division

pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of the Code

of Federal Regulations, Title 40, Part 70.

This Permit is effective upon issuance and expires on April 30, 2012.

_____________________________________

Director, Air Resources Division

Page 2: TITLE V OPERATING PERMIT · 2010. 8. 9. · NG Natural Gas NHDES ... Model VC-4 Serial Number 4759 Nat Com Burner Model DBG 582R Serial Number 9511-1 2004 66.3 MMBtu/hr Natural gas,

TV-OP-010 Page 2 of 44

University of New Hampshire

TABLE OF CONTENTS

ABBREVIATIONS ..............................................................................................................3

ABBREVIATIONS (cont.) ..................................................................................................4

Facility Specific Title V Operating Permit Conditions.....................................................5

I. Facility Description of Operations:....................................................................................................5

II. Permitted Activities: ..........................................................................................................................5

III. Significant Activities Identification:..............................................................................................5

A. Significant Activities: ....................................................................................................................5

B. Stack Criteria: ................................................................................................................................7

IV. Insignificant Activities Identification: ...........................................................................................7

V. Exempt Activities Identification: .......................................................................................................7

VI. Pollution Control Equipment/Technique Identification: ...............................................................7

VII. Alternative Operating Scenarios: ...................................................................................................8

VIII. Applicable Requirements:..............................................................................................................8

A. State-only Enforceable Operational and Emission Limitations:....................................................8

B. Federally Enforceable Operational and Emission Limitations ......................................................9

C. Emission Reductions Trading Requirements...............................................................................14

D. Monitoring and Testing Requirements: .......................................................................................14

E. Recordkeeping Requirements: .....................................................................................................25

F. Reporting Requirements: .............................................................................................................29

IX. Requirements Currently Not Applicable: ....................................................................................32

General Title V Operating Permit Conditions ................................................................33

X. Issuance of a Title V Operating Permit............................................................................................33

XI. Title V Operating Permit Renewal Procedures............................................................................33

XII. Application Shield .......................................................................................................................33

XIII. Permit Shield................................................................................................................................33

XIV. Reopening for Cause................................................................................................................34

XV. Administrative Permit Amendments............................................................................................34

XVI. Operational Flexibility.............................................................................................................34

XVII. Minor Permit Amendments......................................................................................................36

XVIII. Significant Permit Amendments ..............................................................................................36

XIX. Title V Operating Permit Suspension, Revocation or Nullification ........................................37

XX. Inspection and Entry ....................................................................................................................37

XXI. Certifications............................................................................................................................37

A. Compliance Certification Report .................................................................................................37

B. Certification of Accuracy Statement............................................................................................38

XXII. Enforcement.............................................................................................................................38

XXIII. Emission-Based Fee Requirements..........................................................................................39

XXIV. Duty To Provide Information...................................................................................................40

XXV. Property Rights ........................................................................................................................40

XXVI. Severability Clause ..................................................................................................................40

XXVII. Emergency Conditions.........................................................................................................40

XXVIII. Permit Deviation ..................................................................................................................41

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TV-OP-010 Page 3 of 44

University of New Hampshire

ABBREVIATIONS

AAL Ambient Air Limit

AP-42 Compilation of Air Pollutant Emission Factors

ARD Air Resources Division

ASTM American Society for Testing and Materials

BHP Break Horse Power

BSEG Black Start Emergency Generator

BTU British Thermal Units

CAA Clean Air Act

CAS Chemical Abstract Service

CEMS Continuous Emission Monitoring System

CF Cubic Foot (ft3)

CFR Code of Federal Regulations

CGA Cylinder Gas Audit

CO Carbon monoxide

CO2 Carbon Dioxide

COMS Continuous Opacity Monitoring System

CT Combustion Turbine

DB Duct Burner

DER Discrete Emission Reduction

EG Emergency Generator

Env-A New Hampshire Code of Administrative Rules – Air Resources Division

ERC Emission Reduction Credit

FR Federal Register

Ft3 Cubic foot

Gal Gallon

HAP Hazardous Air Pollutant

HCl Hydrochloric acid

hr hour

HRSG Heat Recovery Steam Generator

kGal 1,000 gallons

KW Kilo Watt

lb/hr pounds per hour

LPG Liquid Petroleum Gas (Propane)

mg/L Milligrams per liter (ppm)

MMBTU Million British Thermal Units

MMCF Million Cubic Feet

MW Mega Watt

NA Not Available

NAAQS National Ambient Air Quality Standard

NESHAPs National Emissions Standards for Hazardous Air Pollutants

NG Natural Gas

NHDES (or DES) New Hampshire Department of Environmental Services NOx Oxides of Nitrogen

NSPS New Source Performance Standard

NSR New Source Review

Page 4: TITLE V OPERATING PERMIT · 2010. 8. 9. · NG Natural Gas NHDES ... Model VC-4 Serial Number 4759 Nat Com Burner Model DBG 582R Serial Number 9511-1 2004 66.3 MMBtu/hr Natural gas,

TV-OP-010 Page 4 of 44

University of New Hampshire

ABBREVIATIONS (cont’d.)

PM Particulate Matter

PM10 Particulate Matter less than 10 microns diameter

ppm part per million

ppmvd part per million by volume dry basis

PSD Prevention of Significant Deterioration

PSI Pounds per Square Inch

PTE Potential to Emit

RAA Relative Accuracy Audit

RACT Reasonably Available Control Technology

RATA Relative Accuracy Test Audit

RSA Revised Statues Annotated

RTAP Regulated Toxic Air Pollutant

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAP Toxic Air Pollutant

TSP Total Suspended Particulate Matter

TPY Tons per Year

USEPA United States Environmental Protection Agency

VOC Volatile Organic Compound

Page 5: TITLE V OPERATING PERMIT · 2010. 8. 9. · NG Natural Gas NHDES ... Model VC-4 Serial Number 4759 Nat Com Burner Model DBG 582R Serial Number 9511-1 2004 66.3 MMBtu/hr Natural gas,

TV-OP-010 Page 5 of 44

University of New Hampshire

Facility Specific Title V Operating Permit Conditions

I. Facility Description of Operations:

The University of New Hampshire, Durham Campus (UNH) is an educational institution located in Durham,

NH. The predominant source of air pollutant emissions at UNH is its central heating plant, a boiler located

in the New England Center, a combustion turbine with supplemental heat recovery steam generator, and

emergency generators located throughout the facility.

II. Permitted Activities:

In accordance with all of the applicable requirements identified in the Permit, the Permittee is authorized to

operate the devices and/or processes identified in Sections III, IV, V, and VI within the terms and conditions

specified in this permit.

III. Significant Activities Identification:

A. Significant Activities:

The activities identified in Table 1 are subject to and regulated by this Title V Operating Permit.

Table 1 – Significant Activity Identification

Emission

Unit ID Description of Emission Unit

Installation

Date Emissions Unit Maximum Design/Permitted

Capacity

EU1 Boiler #1 (Central Heating Plant)

Babcock & Wilcox

Model FF2972

Serial Number NA

1963 47.3 MMBtu/hr1

a) No. 6 fuel oil, equivalent to 315.3 gal/hr; or

b) Natural gas, equivalent to 46,373 scf/hr

EU2 Boiler #2 (Central Heating Plant)

Babcock & Wilcox

Model FF2972

Serial Number NA

1963 47.3 MMBtu/hr

a) No. 6 fuel oil, equivalent to 315.3 gal/hr; or

b) Natural gas, equivalent to 46,373 scf/hr

EU3 Boiler #3 (Central Heating Plant)

Babcock & Wilcox

Model FF2713

Serial Number NA

1958 47.3 MMBtu/hr

a) No. 6 fuel oil, equivalent to 315.3 gal/hr; or

b) Natural gas, equivalent to 46,373 scf/hr

EU4 Boiler #4 (Central Heating Plant)

Riley

Model NA

Serial Number NA

1948 47.3 MMBtu/hr

a) No. 6 fuel oil, equivalent to 315.3 gal/hr; or

b) Natural gas, equivalent to 46,373 scf/hr

EU5 Boiler #5 (Central Heating Plant)

Cleaver Brooks

Model CB-600-400

Serial Number NA

1986 16.7 MMBtu/hr

a) No. 6 fuel oil, equivalent to 111.7 gal/hr; or

b) Natural gas, equivalent to 16,373 scf/hr

1 The heating values of Diesel fuel, No. 6 fuel oil, No. 2 fuel oil, and natural gas are assumed to be equal to 137,000 Btu/gal, 150,000

Btu/gal, 140,000 Btu/gal, and 1,020 Btu/scf, respectively.

Page 6: TITLE V OPERATING PERMIT · 2010. 8. 9. · NG Natural Gas NHDES ... Model VC-4 Serial Number 4759 Nat Com Burner Model DBG 582R Serial Number 9511-1 2004 66.3 MMBtu/hr Natural gas,

TV-OP-010 Page 6 of 44

University of New Hampshire

Table 1 – Significant Activity Identification

Emission

Unit ID Description of Emission Unit

Installation

Date Emissions Unit Maximum Design/Permitted

Capacity

EU6 New England Center Boiler

Cleaver Brooks

Model CB-662-300

Serial Number NA

1965 12.6 MMBtu/hr

a) No. 2 fuel oil, equivalent to 89.5 gal/hr; or

b) Natural gas, equivalent to 12,353 scf/hr

EU7 Combustion Turbine

Alstom Power

Model Tempest

Serial Number NA

2004 104.8 MMBtu/hr using No. 2 fuel oil at 0 deg F

with the Chiller OFF2, equivalent to 748.6 gal/hr

No. 2 fuel oil;

106.0 MMBtu/hr using Natural gas at 0 deg F

with the Chiller OFF, equivalent to 103,922

scf/hr Natural gas

EU8 Heat Recovery Steam Generator

With Duct Burner

Energy Recovery International

Model VC-4

Serial Number 4759

Nat Com Burner

Model DBG 582R

Serial Number 9511-1

2004 66.3 MMBtu/hr

Natural gas, equivalent to 66,300 scf/hr

EU9 Black Start Emergency Generator3 at the

Combustion Turbine Building

Caterpillar

Model 3412/SR4B

Serial Number BLG02735

750 KW

2004 7.5 MMBtu/hr

Diesel fuel, equivalent to 54.8 gal/hr

EU10 Emergency Generators (EG1 through

EG7 listed in Attachment A) which are

included in the facility wide emissions

cap along with EU1 through EU9.

Prior to

1999

See Attachment A

EU11 See Attachment A for a list of all

emergency Generators on the UNH

campus above permitting thresholds of

1.5 MMBtu/hr gross heat input rate

combined for liquid fuels and 10.0

MMBtu/hr gross heat input rate

combined for gaseous fuels, and which

individually are above 150,000 Btu/hr

gross heat input rate.

See

Attachment

A

See Attachment A

2 The Combustion Turbine has an Absorption Chiller to provide combustion air pre-cooling for the Combustion Turbine. This

operates whenever the ambient air temperature is above 70 degrees F and the Turbine can not meet the campus electrical load. 3 The Black Start Emergency Generator (EU9) is listed as EG8 in the table of all emergency generators at the facility above 150,000

Btu/hr in Attachment A of this permit.

Page 7: TITLE V OPERATING PERMIT · 2010. 8. 9. · NG Natural Gas NHDES ... Model VC-4 Serial Number 4759 Nat Com Burner Model DBG 582R Serial Number 9511-1 2004 66.3 MMBtu/hr Natural gas,

TV-OP-010 Page 7 of 44

University of New Hampshire

B. Stack Criteria:

The stacks listed in Table 2 – Stack Criteria, for the significant devices described in Table 1 and

listed below, shall discharge vertically without obstruction (including rain caps) and meet the

following criteria in accordance with the state requirements4 of Env-A 606.

Table 2 – Stack Criteria

Stack # Emission Unit ID

Minimum Stack

Height (Feet Above

Ground Level)

Maximum Exit

Diameter

(Feet)

Stack #1 EU1, EU2, EU3, and

EU4 (Combined Stack)

205 8.5

Stack #2 EU5 50 3.0

Stack #3 EU6 35 2.0

Stack #4 EU7/EU8 100 5.0

A. The owner or operator may change the stack criteria described in Table 2 without obtaining

approval from DES provided that:

1. An air-quality impact analysis is performed either by the facility or DES (if requested by the

facility in writing) in accordance with Env-A 606 and the “Guidance and Procedures for

Performing Air Quality Impact Modeling in New Hampshire”, and

2. The analysis demonstrates that emissions from the modified stack will continue to comply

with all applicable emission limitations and ambient air limits.

B. All air modeling data and analyses shall be kept on file at the facility for review by DES upon

request.

IV. Insignificant Activities Identification:

All activities at this facility that meet the criteria identified in Env-A 609.04 shall be considered

insignificant activities. Emissions from the insignificant activities shall be included in the total facility

emissions for the emission-based fee calculation described in Section XXIII of this Permit.

V. Exempt Activities Identification:

All activities identified in Env-A 609.03(c) shall be considered exempt activities and shall not be included

in the total facility emissions for the emission based fee calculation described in Section XXIII of this

permit.

VI. Pollution Control Equipment/Technique Identification:

The devices and/or processes identified in Table 1 do not operate with any add-on pollution control

equipment.

4 The term “state requirement” is used to refer to those requirements that are not federally enforceable but are state requirements as

defined in Env-A 101.184.

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TV-OP-010 Page 8 of 44

University of New Hampshire

VII. Alternative Operating Scenarios:

No alternative operating scenarios were identified in this permit.

VIII. Applicable Requirements:

A. State Enforceable Operational and Emission Limitations:

The Permittee shall be subject to the state enforceable operational and emission limitations

identified in Table 3 below.

Table 3 – State Enforceable Operational and Emission Limitations

Item

# Applicable Requirements

Applicable

Emission Unit

Regulatory

Citation

1. Required Emission Reductions From Class B Major Sources

Annual sulfur dioxide emissions from each Class B major source, shall have an

average calendar year emission rate not to exceed 1.6 pounds of sulfur dioxide

per million Btu heat input, equivalent to No. 6 fuel oil with 1.5 percent sulfur by

weight, which is 75 percent of the baseline average emission rate for Class B

major sources.

Facility Wide Env-A 403.01

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TV-OP-010 Page 9 of 44

University of New Hampshire

B. Federally Enforceable Operational and Emission Limitations

The Permittee shall be subject to the federally enforceable operational and emission limitations

identified in Tables 4a and 4b below:

Table 4a – Federally Enforceable Operational and Emission Limitations

Item

# Applicable Requirement

Applicable

Emission Unit

Regulatory

Citation

1. Maximum Sulfur Content Allowable in Liquid Fuels

The sulfur content of No. 2 fuel oil shall not exceed 0.40 percent sulfur by

weight.

Facility Wide Env-A

1604.01(a) &

Temporary

Permit

FP-T-0110

2. Maximum Sulfur Content Allowable in Gaseous Fuels

The sulfur content of natural gas shall not exceed 15 grains of sulfur per 100

cubic feet of gas, calculated as hydrogen sulfide at standard temperature and

pressure.

Facility Wide Env-A

1605.01(a) &

Temporary

Permit

FP-T-0110

3. The facility netted out of Non-attainment New Source Review (NSR) and

Prevention of Significant Deterioration (PSD) program requirements by

accepting federally enforceable criteria pollutant emissions caps for EU5

(Boiler 5 at the Central Heating Plant) listed below:

SO2 = 35.29 tpy - (PSD applicability threshold = 40 tpy)

NOx = 8.24 tpy - (PSD applicability threshold = 40 tpy)

CO = 0.75 tpy - (PSD applicability threshold = 100 tpy)

TSP = 2.55 tpy - (PSD applicability threshold = 25 tpy)

PM10 = 2.19 tpy - (PSD applicability threshold = 15 tpy)

EU5 40 CFR 52.21

Avoidance

4. The facility netted out of NSR and PSD program requirements via accepting

federally enforceable emissions caps for combined emissions from EU1 through

EU10. See Attachment A of Temporary Permit FP-T-0110 for an explanation

of the netting analysis and how the criteria pollutant emission caps were

established. Facility wide caps do not contain emissions from insignificant

boilers, insignificant emergency generators, fuel oil storage sources, and/or

miscellaneous insignificant VOC sources. These criteria pollutant emission

caps became effective on June 1, 2006, when EU7, EU8, and EU9 were

operational and began to emit a particular pollutant, in accordance with 40 CFR

52.21(b)(3)(viii). Criteria pollutant emissions caps for EU1 through EU10

combined for consecutive 12-month periods for the criteria pollutants and

sulfuric acid (H2SO4) mist are listed below:

NOx = 77.83 tons per consecutive 12 month period

SO2 = 257.20 tons per consecutive 12 month period

CO = 106.34 tons per consecutive 12 month period

VOC = 25.74 tons per consecutive 12 month period

PM10 = 30.81 tons per consecutive 12 month period

H2SO4 Mist = 6.90 tons per consecutive 12 month period

EU1 through

EU10

40 CFR 52.21

Avoidance &

Temporary

Permit

FP-T-0110

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TV-OP-010 Page 10 of 44

University of New Hampshire

Table 4a – Federally Enforceable Operational and Emission Limitations

Item

# Applicable Requirement

Applicable

Emission Unit

Regulatory

Citation

5. The facility is opting out of NOx RACT requirements for emergency generators

in Env-A 1211.11 by keeping the combined theoretical potential to emit NOx

emissions below 25 tons per consecutive 12 month period by taking a 275 hour

per year limitation for each Emergency Generator at the facility. Note that this

is more stringent than Env-A 1211.01(j)(1), which calls for restricting hours of

operation to less than 500 hours.

EU9, EU10, &

EU11

Env-A 1211.01(j)

& Temporary

Permit

FP-T-0110

6. All emergency generators at the facility shall only operate:

a) As a mechanical or electrical power source and only when the primary

power source for the Facility has been lost during an emergency such as a

power outage; or

b) During normal maintenance and testing as recommended by the

manufacturer.

EU9, EU10, &

EU11

Env-A

1211.02(o) &

Temporary

Permit

FP-T-0110

7. NOx RACT Emission Standards for Combustion Turbines

NOx emissions from the Combustion Turbine (CT) shall be less than or equal to

25 ppmvd at 15% oxygen or 0.092 lb/MMBtu while firing natural gas. Note

that this is more stringent than the NOx emissions limit in 40 CFR 60 Subpart

GG Section 60.332.

EU7 Env-A

1211.06(d) &

Temporary

Permit

FP-T-0110

8. NOx RACT Emission Standards for Combustion Turbines

NOx emissions from the CT shall be less than or equal to 65 ppmvd at 15%

oxygen or 0.253 lb/MMBtu while firing oil.

EU7 Env-A

1211.06(c)(1)b.2.

& Temporary

Permit

FP-T-0110

9. Visible Emission Standard for Fuel Burning Devices Installed on or Prior to

May 13, 1970

No owner or operator shall cause or allow average opacity from fuel burning

devices in excess of 40 percent for any continuous 6 minute period in any 60

minute period.

EU1 through

EU4 & EU6

Env-A 1202.01

&

Env-A 2002.015

(eff. 4-23-05)

10. Visible Emission Standard for Fuel Burning Devices Installed After May 13,

1970

No owner or operator shall cause or allow average opacity from fuel burning

devices in excess of 20 percent for any continuous 6 minute period in any 60

minute period.

EU5, EU7,

EU8, EU9,

EU10, &

EU11

Env-A 1202.02

&

Env-A 2002.02

(eff. 4-23-05) &

Temporary

Permit

FP-T-0110

5 Env-A 2002 was formerly Env-A 1200, contained in the EPA-approved State Implementation Plan.

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TV-OP-010 Page 11 of 44

University of New Hampshire

Table 4a – Federally Enforceable Operational and Emission Limitations

Item

# Applicable Requirement

Applicable

Emission Unit

Regulatory

Citation

11. Activities Exempt from the Visible Emission Standard

For those steam generating units subject to 40 CFR 60, i.e., the CT and Duct

Burner (DB) on the Heat Recovery Steam Generator (HRSG), no more than one

of the following 2 exemptions shall be taken:

a) During periods of startup, shutdown and malfunction, average opacity

shall be allowed to be in excess of 20 percent for one period of 6

continuous minutes in any 60 minute period; or

b) During periods of normal operation, average opacity shall be allowed to

be in excess of 20 percent but not more than 27 percent for one period of

6 continuous minutes in any 60 minute period.

EU7 & EU8 Env-A

2002.04(a)

(eff. 4-23-05) &

Temporary

Permit

FP-T-0110

12. Activities Exempt from the Visible Emission Standard

Exceedances of the opacity standard shall not be considered violations of this

chapter if the source demonstrates to the department that such exceedances

were the result of the adherence to good boiler operating practices which, in the

long term, results in the most efficient or safe operation of the boiler.

Exceedances of the opacity standard shall not be considered violations of this

chapter if the source demonstrates to the department that such exceedances

were the result of the occurrence of an unplanned incident in which the opacity

exceedance was beyond the control of the operator and that in response to such

an incident, the operator took appropriate steps in conformance with good boiler

operating practice to eliminate the excess opacity as quickly as possible.

EU7 & EU8 Env-A

2002.04(d),(f)

(eff. 4-23-05) &

Temporary

Permit

FP-T-0110

13. Particulate Emission Standards for Fuel Burning Devices Installed on or Prior

to May 13, 1970

No owner or operator shall cause or allow emissions of particulate matter from

fuel burning devices installed on or prior to May 13, 1970 in excess of the rates

set forth below, where:

For devices with I (maximum gross heat input rate in MMBtu/hr) equal to or

greater than 10 but less than 10,000, E (the maximum allowable particulate

matter emission rate in lb/MMBtu) shall be calculated by raising I to the –0.166

power, and multiplying the result by 0.880, expressed mathematically in the

formula below:

E = 0.880 * I-0.166

EU1 through

EU4 & EU6

Env-A

2002.06(c)(2)

(eff. 4-23-05)

14. Particulate Emission Standards for Fuel Burning Devices Installed on or After

January 1, 1985

No owner or operator shall cause or allow emissions of particulate matter from

fuel burning devices installed on or after January 1, 1985 in excess of 0.30

lb/MMBtu.

EU5,

EU7/EU8,

EU9, EU10, &

EU11

Env-A

2002.08(c)(1)

(eff. 4-23-05) &

Temporary

Permit

FP-T-0110

15. The CT emissions shall be limited to less than 0.015 percent sulfur dioxide by

volume at 15 percent oxygen and on a dry basis and no fuel shall be burned in

the CT which contains sulfur in excess of 0.8 percent by weight

EU7 40 CFR 60

Subpart GG

Section 60.333(a)

& (b)

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TV-OP-010 Page 12 of 44

University of New Hampshire

Table 4a – Federally Enforceable Operational and Emission Limitations

Item

# Applicable Requirement

Applicable

Emission Unit

Regulatory

Citation

16. Accidental Release Program Requirements

The quantities of regulated chemicals stored at the facility are less than the

applicable threshold quantities established in 40 CFR 68.130. The facility is

subject to the Purpose and General Duty clause of the 1990 Clean Air Act,

Section 112(r)(1). General Duty includes the following responsibilities:

a) Identify potential hazards which result from such releases using appropriate

hazard assessment techniques;

b) Design and maintain a safe facility;

c) Take steps necessary to prevent releases; and

d) Minimize the consequences of accidental releases that do occur.

Facility Wide CAA Section

112(r)(1)

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TV-OP-010 Page 13 of 44

University of New Hampshire

Table 4b – Federally Enforceable Emissions Limitations

Device NOx SO2 PM10 CO VOC H2SO4 Mist

EU5 8.24 tpy 35.29 tpy 2.19 tpy

PM10 &

2.55 tpy TSP

0.75 tpy No limit No limit

EU7 (gas) 25 ppmvd at

15% O2 or

0.092

lb/MMBtu

0.0043

lb/MMBtu

2.12 lb/hr6

or

0.0319

lb/MMBtu

0.1122

lb/MMBtu

0.0321

lb/MMBtu

0.0003

lb/MMBtu

EU7 (oil) 65 ppmvd at

15% O2 or

0.253

lb/MMBtu

0.3903

lb/MMBtu

5.25 lb/hr7

or

0.0804

lb/MMBtu

0.1150

lb/MMBtu

0.033

lb/MMBtu

0.030

lb/MMBtu

EU7 (gas) &

EU8 (gas)8

0.1019

lb/MMBtu or

17.55 lb/hr

0.0044

lb/MMBtu

or

0.75 lb/hr

0.01949

lb/MMBtu

or

2.6 lb/hr

0.1084

lb/MMBtu

or

18.67 lb/hr

0.0288

lb/MMBtu

or

4.97 lb/hr

0.00034810

lb/MMBtu

or

0.06 lb/hr

EU7 (oil) &

EU8 (gas)11

0.2005

lb/MMBtu

or

34.31 lb/hr

0.2408

lb/MMBtu

or

41.19 lb/hr

0.043312

lb/MMBtu

or

5.8 lb/hr

0.1101

lb/MMBtu

or

18.83 lb/hr

0.0293

lb/MMBtu

or

5.02 lb/hr

0.018713

lb/MMBtu

or

3.2 lb/hr

EU914 7.17

gram/bHP-hr

or 15.9 lb/hr

0.40

lb/MMBtu or

3.10 lb/hr

0.06

lb/MMBtu or

0.48 lb/hr

0.39

lb/MMBtu or

2.97 lb/hr

0.07

lb/MMBtu or

0.55 lb/hr

No limit

Facility Wide

Caps15

77.83 tpy 257.20 tpy 30.81 tpy 106.34 tpy 25.74 tpy 6.90 tpy

6 Maximum short term (lb/hr) PM10 emissions of 2.12 lb/hr from the CT firing natural gas occur at 0 deg F at any load, per vendor

guarantee. Note that the 0.0319 lb/MMBtu value is for operation of the CT at 62.1 MMBtu/hr at 45 deg F, the worst case short term

emissions of PM10 from the CT in terms of lb/MMBtu. 7 Maximum short term PM10 emissions of 5.25 lb/hr from the CT firing No. 2 fuel oil occur at 0 deg F at any load, per vendor

guarantee. Note that the 0.0804 lb/MMBtu value is for operation of the CT at 60.9 MMBtu/hr at 45 deg F, the worst case short term

emissions of PM10 from the CT in terms of lb/MMBtu. 8 Maximum gross heat input rate for CT on gas is 106.0 MMBtu/hr and DB on gas is 66.3 MMBtu/hr. 9 Maximum combined PM10 emissions of 2.6 lb/hr occur when the CT is firing gas at any load while at 0 deg F, per vendor guarantee.

Maximum combined PM10 emissions in lb/MMBtu occur when the CT is at a lower load (67.8 MMBtu/hr) firing natural gas at 0 deg

F, with the HRSG at its maximum heat input rate of 66.3 MMBtu/hr on natural gas. 10 CT at 106 MMBtu/hr and HRSG at 66.3 MMBtu/hr with ambient air temperature of 0 deg F and Chiller Off. 11 Maximum gross heat input rate for CT on No. 2 fuel oil is 104.8 MMBtu/hr and DB on gas is 66.3 MMBtu/hr. 12 Maximum combined PM10 emissions of 5.8 lb/hr occur when the CT is firing No. 2 fuel oil at any load while at 0 deg F, per vendor

guarantee. Maximum combined PM10 emissions in lb/MMBtu occur when the CT is at a lower load (67.6 MMBtu/hr) firing No. 2

fuel oil at 0 deg F, with the HRSG at its maximum heat input rate of 66.3 MMBtu/hr on natural gas. 13 CT at 104.8 MMBtu/hr on natural gas, HRSG at 66.3 MMBtu/hr with ambient temperature of 0 deg F and Chiller Off. 14 Black Start Emergency Generator (referred to as EU9 in Table 1 of this permit and EG8 in Attachment A) is located at the

Combustion Turbine Plant, emissions limitations were established in the Temporary Permit FP-T-0110. 15 Facility wide caps include EU1 through EU8 plus EU9 and EU10 plus contemporaneous additions of 5 small emergency generators

and 12 small building furnace/boilers, which are all listed in Attachment B of this Title V Operating Permit.

Page 14: TITLE V OPERATING PERMIT · 2010. 8. 9. · NG Natural Gas NHDES ... Model VC-4 Serial Number 4759 Nat Com Burner Model DBG 582R Serial Number 9511-1 2004 66.3 MMBtu/hr Natural gas,

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University of New Hampshire

C. Emission Reductions Trading Requirements

UNH was granted 33 Emissions Reductions Credits (14 for use during ozone season and 19 for

use during non-ozone season) via Certificate No. 97NUNH02C for the shutdown of

Consummate Incinerators 1, 2, & 3. The 33 ERCs shall be valid provided that the credited

reductions remain real, quantifiable, surplus, enforceable, and permanent and provided that the

Permittee complies with all of the following legally enforceable conditions:

1. UNH is subject to Env-A 3000 and the approved NOx ERCs Creation Protocol;

2. UNH shall not operate Consummate Incinerators 1, 2, & 3;

3. These ERCs, generated from the shutdown of the Consummate Incinerators, shall only be

used by UNH, and UNH may not sell, transfer, or trade these ERC’s; and

4. UNH shall not use these ERCs prior to obtaining written consent from DES, in accordance

with Env-A 3006 and 3007.

UNH also generated credits for the gas conversion of Boilers 1-5. UNH is authorized under the

applicable requirements of Env-A 3100 (the Discrete Emissions Reductions (DERs) Trading

Program) to trade seven 1997 ozone season and thirteen non-ozone season DERs. Additional

DERs may be traded upon submittal of Notices of Generation of DERs for periods after 1997.

Upon submittal, said Notices shall be available to the public under RSA 91-A.

D. Monitoring and Testing Requirements:

The Permittee is subject to the monitoring and testing requirements as contained in Table 5 below:

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

1. NOx RACT

Annual Boiler

Tune-ups

NOx RACT Annual Boiler Tune-up

Annually, the owner or operator shall:

a) Perform an efficiency test using the test

procedures specified in Chapter 3, Combustion

Efficiency Tables, Taplin, Harry R., Fairmont

Press, 1991; and

b) Adjust the combustion process of the boiler in

accordance with the procedures specified in

Chapter 5, Combustion Efficiency Tables,

Taplin, Harry R., Fairmont Press, 1991.

Annually, or

within 60

days of

startup if a

unit has been

out of service

for 12

consecutive

months or

longer

EU1

through

EU6

Env-A

1211.05(b)(1)

2. Fuel

Monitoring

Fuel flow monitors and recorders shall be installed,

maintained, and operated on the natural gas inlet

lines to the CT and DB. The systems shall at a

minimum be capable of giving instantaneous flow

measurements and recording total daily (continuous

24 hour period) fuel usage for the emissions device.

The owner or operator shall follow the

manufacturer’s recommended calibration and

preventative maintenance procedures.

Instantaneous

& Daily

Total

Consumption

EU7 &

EU8

Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

3. Fuel

Monitoring

A fuel flow monitor and recorder shall be installed,

maintained, and operated on the fuel oil inlet line to

the CT. The system shall at a minimum be capable

of giving instantaneous flow measurements and

recording total daily (continuous 24 hour period) fuel

usage for the CT. The owner or operator shall follow

the manufacturer’s recommended calibration and

preventative maintenance procedures.

Instantaneous

& Daily

Total

Consumption

EU7 Temporary

Permit

FP-T-0110

4. Hours of

Operation for

the BSEG

A non-resettable hour meter/totalizer shall be

installed, maintained, and operated on the BSEG.

The system shall be capable of recording and

totalizing hours of operation of the BSEG. The

owner or operator shall follow the manufacturer’s

recommended calibration and preventative

maintenance procedures.

Continuous

hours of

operation

EU9 Temporary

Permit

FP-T-0110

5. Custom Fuel

Monitoring for

CT (natural

gas)

a) No monitoring of fuel nitrogen is required so

long as the facility is supplied with solely

pipeline-quality natural gas or LNG.

b) No monitoring of sulfur content is required for

pipeline natural gas that meets the definition of

natural gas in 40 CFR 60 Section 60.331(u),

i.e., is less than or equal to 20 grains of sulfur

per 100 cubic feet of natural gas. The owner

or operator is required to keep records of the

gas quality characteristics in a current, valid

purchase contract, tariff sheet or transportation

contract for the gaseous fuel, specifying that

the maximum total sulfur content of the fuel is

20.0 grains/100 scf or less. The owner or

operator can also use representative fuel

sampling and analysis data from its

performance test to show the sulfur content of

the pipeline natural gas is less than or equal to

20.0 grains/100 scf.

As specified EU7 40 CFR 60

Subpart GG

Section

60.334(h)(3)

& Temporary

Permit

FP-T-0110

6. Custom Fuel

Monitoring for

CT (No. 2 fuel

oil)

The owner or operator shall be required to do the

following monitoring of No. 2 fuel oil for

consumption by the Combustion Turbine: For each

delivery of No. 2 fuel oil, the owner or operator shall

conduct testing using the appropriate ASTM Method

or retain certified delivery tickets from the fuel oil

supplier which state the weight percent of sulfur and

fuel bound nitrogen content to determine compliance

with the sulfur and nitrogen content limitations

required by 40 CFR 60 Subpart GG in this permit for

liquid fuels.

As specified EU7 Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

7. CT NOx

CEMS

Requirements

The owner or operator shall install, operate,

maintain, and perform quality assurance testing of a

CEM system meeting all of the requirements

specified in Items 8 through 15 of Table 5 if any of

the following conditions exists: The owner or

operator of a source chooses to limit its potential to

emit by accepting federally enforceable permit

conditions that restrict its hours of operation, the type

or amount of material combusted, stored, or

processed, or its level of production, and continuous

emission monitoring is determined by the division to

be necessary to ensure that these permit conditions

are not violated

As specified EU7 Env-A

808.02(a)(2)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

8. CT NOx

CEMS

Minimum

Specifications

for CEM

Systems

a) A CEM system for measuring gaseous

emissions shall average and record the data for

each calendar hour;

b) All CEM systems, opacity and gaseous

measuring included, shall:

1. Include a means to display instantaneous

values of percent opacity and gaseous

emission concentrations; and

2. Complete a minimum of one cycle of

operation, which shall include

measurement, analyzing, and data recording

for each successive 5-minute period for

systems measuring gaseous emissions and

each 10-second period for systems

measuring opacity, unless a longer time

period is approved in accordance with Env-

A 809;

c) A stack volumetric flow measuring device

required to be installed after January 1, 1992,

shall meet the following requirements:

1. All differential pressure flow monitors

shall have an automatic blow-back purge

system installed, and in wet stack

conditions, shall have the capability for

drainage of the sensing lines; and

2. The stack flow monitoring system shall

have the capability for manual calibration of

the transducer while the system in on-line

and for a zero check; and

d) Alternatives to in-stack flow monitoring

devices for determination of stack volumetric

flow rate may be used if the owner or operator

provides the Division with technical

justification that the alternative can meet the

same requirements for data availability, data

accuracy, and quality assurance as an in-stack

device.

As specified EU7 Env-A

808.03(a), (c),

(d), & (e)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

9. NOx CEM

QA/QC Plan

Requirements

The owner or operator is required to develop a

QA/QC plan for the NOx CEM system. A copy must

be filed with the Division within 30 days of

completion of the performance specification testing

of the NOx CEM. It must be reviewed at least once

annually and updated. Within 30 days of completion

of the QA/QC plan annual review, the owner or

operator must certify in writing to the Division that

the owner or operator will continue to implement the

source’s existing QA/QC plan or submit in writing

any changes to the plan and the reason for each

change. The QA/QC plan shall be considered an

update to the CEM monitoring plan required by Env-

A 808.04.

As specified EU7 Env-A

808.06(a) &

(c)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

10. NOx CEM

General Audit

Requirements

a) Required quarterly audits shall be done

anytime during each calendar quarter, but

successive quarterly audits shall occur no more

than 4 months apart;

b) Within 30 days following the end of each

quarter, the owner or operator of the source

shall submit to the Division a written summary

report of the results of all required audits that

were performed in that quarter, with the report

format for the NOx CEM system conforming

to that presented in 40 CFR 60 Appendix F,

Procedure 1, Section 7;

c) The owner or operator shall notify the

Division at least 30 days prior to the

performance of a RATA;

d) The Division shall require rescheduling of any

RATA if the staff necessary to observe the

audit are not available; and

e) The owner or operator shall provide at least

two weeks notice prior to any other planned

audit or test procedure.

As specified EU7 Env-A

808.07(a)-(e)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

11. Audit

Requirements

for Gaseous

CEM Systems

For a system monitoring gaseous emissions of SO2,

NOx, O2 or CO2, the quality assurance requirements

and procedures described in 40 CFR 60, Appendix F,

shall apply, with the following additions and

clarifications for Procedure 1 of Appendix F:

a) The owner or operator shall inform the

division of all out of control periods, as

defined in Appendix F, section 4.3, and Env-A

808.01(g), in the emission reports required

pursuant to Env-A 808.11;

b) The owner or operator may perform a RAA, as

defined in 40 CFR 60, Appendix F, in place of

a CGA; and

c) For CEM systems where CGA audits cannot

be performed, the owner or operator shall

perform RAA audits in place of the CGA;

As specified EU7 Env-A

808.08(a)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

12. Audit

Requirements

for Gaseous

CEM Systems

The owner or operator of a stationary source

determining compliance with a mass flow emissions

limit by using a stack flow volumetric monitor or a

fuel flow meter with O2/CO2 measurements to

calculate heat input or stack flow rate, shall conduct

annually a minimum 9-run RATA with the relative

accuracy calculated in the units of the mass

emissions measurement as specified in 40 CFR 60,

Appendices B and F.

As specified EU7 Env-A

808.08(d)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

13. Audit

Requirements

for Gaseous

CEM Systems

For a stationary source using a stack volumetric flow

monitor for the mass flow emissions calculation, the

owner or operator shall also perform one of the audit

options as specified in Env-A 808.08(f)(1) or (2).

As specified EU7 Env-A

808.08(f)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

14. Data

Availability

Requirements

The owner or operator of a source with a CEM shall

operate the NOx CEM at all times during operation

of the CT, except for periods of CEM breakdown,

repairs, calibration checks, preventative

maintenance, and zero/span adjustments. The

percentage CEM data availability for opacity and all

gaseous concentration monitors shall be maintained

at a minimum of 90% on a calendar quarter basis.

The percentage CEM data availability for opacity

and all gaseous concentration monitors shall be

maintained at a minimum of 75% for any calendar

month. The percentage CEM data availability is

calculated as specified in Env-A 808.10(d). If the

percentage data availability requirements can’t be

met for any calendar quarter, the owner or operator is

required to follow the procedures in Env-A

808.10(e)(1) and (2). If the percentage data

availability requirements can’t be met for any 2

consecutive calendar quarters, the owner or operator

is required to follow the procedures in Env-A

808.10(f)(1) and (2) for installing a replacement

CEM or Env-A 808.10(g).

As specified EU7 Env-A

808.10(a)-(g)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

15. CEM Valid

Averaging

Periods

The number of hours of valid CEM data required for

determining a valid averaging period for the different

emission standard periods shall be:

a) For a 24-hr standard emission standard period,

18 hours of valid data.

As specified EU7 Env-A

808.14(a)-(e)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

16. General Stack

Testing

Requirements

The owner or operator shall conduct visible and

gaseous emissions testing conforming to the

following:

a) A compliance stack emissions test shall

conform to the following:

1. The general requirements of 40 CFR

60.8(a), (b), (d), (e), and (f); and

2. The test methods contained in 40 CFR 60

Appendix A, 40 CFR 51 Appendix M, or

any other EPA-promulgated stack test

method.

b) An owner or operator shall sample emissions

at locations and sampling points that will

provide representative measurements of the

actual emissions during source operation at the

time of the test.

c) The owner or operator shall perform a

stratification check at each measurement

location where a determination of a gas

concentration is required.

d) A stratification check shall be accomplished

by measuring the pollutant or diluent, oxygen

or carbon dioxide gas concentration in

accordance with the EPA Emission

Measurement Technical Information Center

Guideline Document, GD-025, Determination

of the Presence of Stratification of Gaseous

Pollutant and Diluent Emissions for

Continuous Emission Monitor or Reference

Method Relative Accuracy Locations, June 21,

1994.

e) If stratification does not exist, a single point

gas/diluent measurement location shall be

acceptable within the inner 50 percent area of

the duct or stack cross section.

f) If stratification exists, the owner or operator

shall obtain samples either at locations across

the stack diameter equivalent to those

specified in 40 CFR 60, Appendix B,

Performance Specification 2, paragraph 3.2, or

the locations specified in 40 CFR 60,

Appendix A, Method 1.

Initial

performance

test

EU7 &

EU8

Env-A

802.02(a)-(f)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

17. Pre-test Notice a) At least 30 days prior to the commencement of

source testing, the owner or operator shall

notify the division, of the date(s) of any

planned compliance stack testing.

b) The division shall require the rescheduling of

any compliance stack emissions test if the staff

necessary to observe the test, are not available.

Initial

performance

test

EU7 &

EU8

40 CFR 60

Subpart A,

Section

60.8(d)

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

18. Pre-Test

Protocol

At least 30 days prior to the commencement of

testing, the Facility shall submit to the Division a

pretest protocol with the information in Env-A

802.04(a) through (o).

Initial

performance

test

EU7 &

EU8

Env-A 802.04

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

19. Pre-Test

Meeting

At least 15 days prior to the test date, the owner or

operator and any contractor retained by the owner or

operator to conduct the test shall meet with a

Division representative or over the telephone. The

details of the test, the testing schedule, and the

process conditions under which the data shall be

collected shall be finalized at the pre-test meeting. A

pre-test meeting may be held less than 15 days prior

to the test date so long as implementation of any

testing or operation changes resulting from the

meeting can be carried out prior to the scheduled test

date and the scheduled test integrity is not

jeopardized.

Initial

performance

test

EU7 &

EU8

Env-A 802.05

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

20. Safe Access to

Sampling

Platforms

The owner or operator must provide for safe access

to sampling stations and provide sampling stations in

accordance with 40 CFR 60 Subpart A, Section

60.8(e).

Initial

performance

test

EU7 &

EU8

40 CFR 60

Subpart A,

Section

60.8(e)

21. Number of

Runs for a

Complete Test

Each performance test shall consist of three separate

runs using the applicable test method.

Initial

performance

test

EU7 &

EU8

40 CFR 60

Subpart A,

Section

60.8(f)

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

22. Repeating a

Compliance

Stack Test

An owner or operator that repeats a compliance stack

test on the same source shall not be required to

submit another pre-test protocol or attend another

pre-test meeting as specified in Env-A 802.04 and

Env-A 802.05, provided that the following

conditions are met:

a) The owner or operator uses the same stack

testing contractor;

b) The owner or operator follows all stack test

and plant operating conditions specified in the

previously accepted pre-test protocol or any

deviations from the previously accepted pre-

test protocol are specified in detail in the letter

described in d) below;

c) The division approved the previous stack test

as submitted by the owner or operator and the

stack testing contractor; and

d) The owner, operator, or stack testing

contractor submits a letter to the division

referencing the previously approved pre-test

protocol and pre-test meeting and identifying

in detail any deviations from the previously

accepted pre-test protocol or pre-test meeting.

Initial

performance

test

EU7 &

EU8

Env-A

802.06(a)-(d)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

23. Scheduling

Changes

a) The owner or operator shall notify the division

by telephone, fax, or electronic mail prior to

any changes in the testing schedule for a

compliance stack test.

b) The owner or operator shall obtain prior

approval from the division, which shall be

based on staff availability, of any new date for

a compliance stack test.

Initial

performance

test

EU7 &

EU8

Env-A

802.07(a) &

(b)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

24. Calibration

Data for Stack

Sampling

Equipment

a) The owner or operator shall provide

calibration data for any sampling equipment

used during the compliance stack testing to the

division upon request during the day of testing.

b) The owner or operator shall provide copies of

all calibration and field test data taken during

the testing, including failed runs, to the

division upon request.

Initial

performance

test

EU7 &

EU8

Env-A

802.08(a) &

(b)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

25. Use of

Alternative

Methods

During a Test

The Division shall approve deviations from the

agreed-upon test method or pre-test protocol if the

following criteria are met:

a) The owner or operator informs division

personnel assigned to the stack test of the

following:

1. The deviation from the testing method or

planned operational mode of the source;

2. The reason(s) for the deviation;

3. The implications of such a deviation; and

4. The owner or operator provides technical

justification showing that allowance of such

deviation will not affect the accuracy of the

compliance stack emissions test.

Initial

performance

test

EU7 &

EU8

Env-A 802.09

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

26. Operating

Conditions

During a Stack

Emission Test

In accordance with 40 CFR 60 Subpart GG and

revisions contained in the Federal Register dated

April 14, 2003 (pages 17990 to 18005), the facility is

required to test the CT while firing No. 2 fuel oil

without the HRSG on line at 90 to 100 percent peak

load for three runs. The facility will repeat this test

procedure with the CT while firing natural gas

without the HRSG on line. In addition, DES is

requiring the facility to test the CT and duct burner

combined with the CT firing No. 2 fuel oil at 90 to

100 percent peak load and the duct burner at 100

percent load on natural gas for three runs. Finally,

the facility will test the CT and duct burner

combined with the CT firing natural gas at 90 to 100

percent peak load and the duct burner at 100 percent

load on natural gas for three runs. The facility shall

test for NOx, CO, %O2 or CO2, PM10, and H2SO4

mist on the CT and duct burner tests.

Initial

performance

test

EU7 &

EU8

40 CFR 60

Subpart A,

Section

60.8(c)

27. Report

Submission

Requirements

The owner or operator shall submit the stack test

emissions report containing all of the information in

Env-A 802.11(c)(1) through (8) to the Division

within 60 days of the completion of the stack testing.

Within 60

days of

completion

of initial

performance

test

EU7 &

EU8

Env-A 802.11

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

28. Monitoring

Electrical

Power

Generation

The owner or operator shall monitor electrical power

generation from its Combustion Turbine in

accordance with either Env-A 3705.01(b)(1) or (2).

All power generation monitors shall be operated and

maintained in accordance with the operating and

maintenance procedures specified by the

manufacturer.

Continuous EU7 Env-A

3705.01(b) &

Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 5 – Monitoring/Testing Requirements

Item

# Parameter Method of Compliance

Frequency

of Method

Applicable

Emission

Unit

Regulatory

Citation

29. Sulfur Content

of Liquid

Fuels

The owner or operator shall conduct testing using the

appropriate ASTM methods or retain certified

delivery tickets which state the weight percent of

sulfur for each delivery of fuel oil to determine

compliance with the sulfur content limitation

provisions in this permit for liquid fuels.

For each

delivery

Facility

Wide

Env-A 806.02

&

Env-A 806.05

(eff. 10-31-02)

E. Recordkeeping Requirements16:

The Permittee shall be subject to the recordkeeping requirements identified in Table 6 below:

Table 6 – Applicable Recordkeeping Requirements

Item

# Applicable Recordkeeping Requirement

Frequency of

Recordkeeping

Applicable

Emission

Unit

Regulatory

Citation

1. Retention of Records

The owner or operator shall retain records of all required

monitoring data, recordkeeping and reporting requirements, and

support information for a period of at least 5 years from the date

of origination.

Retain for a

minimum of 5

years

Facility

Wide

Env-A 902.01 &

40 CFR

70.6(a)(3)(ii)(B)

2. General Recordkeeping Requirements for Combustion Sources

For each fuel burning device at the facility, the owner or operator

shall keep records of fuel utilization in accordance with the

following:

a) Hours of operation of each combustion device;

b) Fuel consumption;

c) Fuel type (e.g., natural gas, liquefied petroleum gas, No. 2

fuel oil, and diesel fuel);

d) Viscosity (for liquid fuels);

e) Sulfur content of any:

1. Gaseous fuel burned in terms of grains sulfur per scf

fuel, or percent sulfur by weight, calculated as hydrogen

sulfide at standard temperature and pressure; and

2. Liquid fuel burned in terms of percent sulfur by weight.

Monthly Facility

Wide

Env-A 903.03

(eff. 10-21-03)

& Temporary

Permit

FP-T-0110

3. General Recordkeeping Requirements for Sources with CEMS

The owner or operator of a stationary source with a certified

continuous emission monitoring system subject to Env-A 800,

shall maintain records in accordance with the provisions of Env-A

800, and all applicable federal regulations.

On a

continuous

basis

EU7 Env-A 903.04

(eff. 10-21-03)

& Temporary

Permit

FP-T-0110

16 New Hampshire rules cited in this section as federally enforceable are contained in the EPA-approved State Implementation Plan

(SIP), or they are awaiting EPA approval and are at least as stringent as the SIP rule. Each citation of a non-SIP rule is followed by

the effective date of that rule.

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University of New Hampshire

Table 6 – Applicable Recordkeeping Requirements

Item

# Applicable Recordkeeping Requirement

Frequency of

Recordkeeping

Applicable

Emission

Unit

Regulatory

Citation

4. General NOx Recordkeeping Requirements:

The owner or operator of any stationary source, area source, or

device subject to this part, shall record the following information

and maintain such records at the facility:

a) Identification of each combustion device;

b) Operating schedule during the high ozone season for

each combustion device identified in a), above, including:

1. Hours of operation per calendar month;

2. Days of operation per calendar month;

3. Number of weeks of operation;

4. Type and amount of fuel burned for each combustion

device;

5. Heat input rate in million BTUs per hour; and

6. The following NOx emission data:

a. Actual NOx emissions from each combustion device

identified in a) above for:

1) Each calendar year, in tons; and

2) A high ozone season day during that calendar

year, in pounds per day; and

c) The emission factors and the origin of the emission

factors used to calculate the NOx emissions.

On a

continuous

basis

Facility

Wide

Env-A 905.02

(eff. 4-23-99) &

Temporary

Permit

FP-T-0110

5. Additional Recordkeeping Requirements

The owner or operator shall maintain a 12-month running total

record of emissions of NOx, SO2, CO, PM10, VOC, and H2SO4

mist from EU1 through EU10 combined, for the purpose of

demonstrating that emissions of these pollutants are below the

caps in Item 4 of Table 4a, which the facility took to net out of

Non-attainment New Source Review and Prevention of

Significant Deterioration program requirements.

On a

continuous

basis

EU1-EU10 Env-A 906 (eff.

4-23-99) &

Temporary

Permit

FP-T-0110

6. NOX RACT Annual Boiler Tune-ups

Maintain in a permanently bound log book the following

information:

a) The date(s) on which:

1. The efficiency test was conducted; and

2. The combustion process was last adjusted.

b) The name(s), title, and affiliation of the person(s) who:

1. Conducted the efficiency test; and

2. Made the adjustments.

c) The NOx emission concentration, in ppmvd, corrected to

15% oxygen, after the adjustments are made;

d) The CO emission concentration, in ppmvd, corrected to

15% oxygen, after the adjustments are made;

e) The opacity readings; and

f) Any other information required by Env-A 903, Env-A 905,

and Env-A 909.

On a

continuous

basis

EU1-EU6 Env-A

1211.05(b)(2)

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University of New Hampshire

Table 6 – Applicable Recordkeeping Requirements

Item

# Applicable Recordkeeping Requirement

Frequency of

Recordkeeping

Applicable

Emission

Unit

Regulatory

Citation

7. a) The owner or operator shall maintain calendar monthly

records of actual NOx emissions in accordance with the

methods set forth in Env-A 620.

b) The owner or operator shall maintain calendar monthly

records of power generation from the CT in accordance

with the following:

1. The measurements of power generation as output on an

instrument recorder;

2. The number of hours of operation of the NOx-emitting

generation source;

3. The number of hours of downtime of the power

generation monitoring system, if applicable, during the

time period when the NOx-emitting generation source is

in operation;

4. Fuel usage; and

5. The frequency and results of calibrations performed, as

applicable.

Monthly EU7 Env-A 3706.01

(eff. 12-20-01)

& Temporary

Permit

FP-T-0110

8. The owner or operator will calculate the NOx emissions reduction

fee by taking the total tons of NOx emissions calculated in

accordance with Env-A 3704 and multiplying by the NOx

emissions reduction fee in dollars per ton for the appropriate time

period from Table 3707-1.

Annually EU7 Env-A 3707.03

(eff. 12-20-01)

& Temporary

Permit

FP-T-0110

9. The owner or operator shall maintain records of:

a) The occurrence and duration of any startup, shutdown, or

malfunction in the operation of the CT and HRSG Unit; or

b) Any periods during which a continuous monitoring system

or monitoring device is inoperative.

As stated EU7 &

EU8

40 CFR 60

Subpart A

Section 60.7(b)

10. The owner or operator shall maintain a file of all measurements,

including:

a) Continuous monitoring system, monitoring device (fuel

flow meter), and performance testing measurements;

b) All continuous monitoring system performance evaluations;

c) All continuous monitoring system or monitoring device

calibration checks;

d) Adjustments and maintenance performed on these systems

or devices; and

e) All other information required by this part recorded in a

permanent form suitable for inspection.

5 year record

retention

EU7 &

EU8

40 CFR 60

Subpart A

Section 60.7(f)

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Table 6 – Applicable Recordkeeping Requirements

Item

# Applicable Recordkeeping Requirement

Frequency of

Recordkeeping

Applicable

Emission

Unit

Regulatory

Citation

11. Monitoring/Testing Data

The owner or operator shall maintain records of monitoring and

testing requirements as specified in Table 5 of this Permit

including but not limited to:

a) Summary reports of stack testing conducted on combustion

devices at the facility; and

b) Summary of testing and/or delivery ticket certifications for

sulfur content limitations in liquid fuel.

Maintain on a

continuous

basis

Facility

Wide

Env-A 902.01

(new rule) &

40 CFR

70.6(a)(3)(iii)(A)

12. Keep copies of records of VOLs stored for a period of two years.

Keep records of tank dimensions and capacity for the life of the

tank. Maintain a record of the VOL stored, the period of storage,

and the maximum true vapor pressure of that VOL during the

respective storage period.

As specified No. 2 Fuel

Oil Storage

Tank

40 CFR 60

Subpart Kb,

Section

60.116b(a-c)

13. The owner or operator shall maintain the following records for All

Emergency Generators located at the facility:

a) Hours of operation;

b) Dates of operation;

c) Monthly and consecutive 12 month fuel use; and

d) Consecutive 12 month hours of operation.

Maintain on a

continuous

basis

EU9,

EU10, &

EU11

Env-A 906

14. Record and maintain records of the types and amounts of fuel

combusted by the Duct Burner each day.

Maintain on a

continuous

basis

EU8 40 CFR 60

Subpart Dc,

Section

60.48c(g)

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University of New Hampshire

F. Reporting Requirements:

The Permittee shall be subject to the reporting requirements identified in Table 7 below:

Table 7 – Applicable Reporting Requirements

Item

# Reporting Requirements

Frequency of

Reporting

Applicable

Emission

Unit

Regulatory

Citation

1. Certification of Accuracy

Any report submitted to the DES and/or EPA shall include

the certification of accuracy statement outlined in Section

XXI.B of this Permit and shall be signed by the responsible

official.

As specified in

this Permit

Facility Wide 40 CFR

70.6(c)(1)

2. NOx Reporting Requirements:

For each combustion device, the owner or operator shall

submit to the director, in accordance with the schedule in

Env-A 909.02(a), reports of the data required pursuant to

Env-A 905.

Annually to DES

(no later than

April 15th

of the

following year)

Facility Wide Env-A 909.03

(eff. 4-23-99) &

Temporary

Permit

FP-T-0110

3. In accordance with Env-A 3704.01(b), a NOx-emitting

generation source (CT #1) shall not be required to pay NOx

emissions reduction fund fees for the first 7 pounds of NOx

emitted for each megawatt-hour of electricity produced. In

addition, the owner or operator may submit a written request

in accordance with Env-A 3703.02 in order to claim

exclusion for NOx emissions attributed to heat recovery from

these devices. To date, the owner or operator has not

submitted a written request.

As stated EU7 Env-A

3704.01(b)

(eff. 12-20-01)

& Temporary

Permit

FP-T-0110

4. The owner or operator shall submit annually to the Division

all information pursuant to Env-A 3706.01 (monthly actual

NOx emissions and monthly power generation for CT) by

April 15th

of the following calendar year.

Initially due

before April 15,

2007 and

thereafter,

annually, by

April 15th

the

following year

EU7 Env-A 3706.02

(eff. 12-20-01)

& Temporary

Permit

FP-T-0110

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University of New Hampshire

Table 7 – Applicable Reporting Requirements

Item

# Reporting Requirements

Frequency of

Reporting

Applicable

Emission

Unit

Regulatory

Citation

5. a) In accordance with Env-A 3707.01(a), in addition to

the fees specified in Env-A 700, all applicable NOx-

emitting generation sources shall pay to the Division

each year, starting in 2006 for NOx emitted in 2005, a

NOx emissions reduction fund fee as calculated

pursuant to Env-A 3707.03.

b) In accordance with Env-A 3707.02, the owner or

operator will submit to the Director with each emission

reduction fund fee payment a description of the method

used to calculate actual emissions with each emission

reduction fee payment.

c) In accordance with Env-A 3707.04, the owner or

operator will pay to the Division the NOx emissions

reduction fund fee annually, in accordance with the

schedule specified in Env-A 705.04 for emission-based

fees.

Annually, by

April 15th

the

following year

EU7 Env-A

3707.01(a),

Env-A 3707.02,

Env-A 3707.04

(eff. 12-20-01)

& Temporary

Permit

FP-T-0110

6. Permit Deviations

Prompt reporting of deviations from Permit requirements

including those attributed to upset conditions as defined in

the Permit, the probable cause of such deviations, and any

corrective actions or preventative measures taken shall be

conducted in accordance with Section XXVIII. of this

Permit.

Prompt reporting

(within 24-hours

of discovery of

an occurrence)

Facility Wide 40 CFR

70.6(a)(3)(iii)(B)

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Table 7 – Applicable Reporting Requirements

Item

# Reporting Requirements

Frequency of

Reporting

Applicable

Emission

Unit

Regulatory

Citation

7. Each owner or operator required to install a continuous

monitoring device shall submit excess emissions and

monitoring systems performance report (excess emissions are

defined in applicable subparts) and-or summary report form

(see Item 3 of this Table) to the USEPA and DES

semiannually, except when: more frequent reporting is

specifically required by an applicable subpart; or the USEPA,

on a case-by-case basis, determines that more frequent

reporting is necessary to accurately assess the compliance

status of the source. All reports shall be postmarked by the

30th day following the end of each six-month period. Written

reports of excess emissions shall include the following

information:

a) The magnitude of excess emissions computed in

accordance with § 60.13(h), any conversion factor(s)

used, and the date and time of commencement and

completion of each time period of excess emissions.

The process operating time during the reporting period.

b) Specific identification of each period of excess

emissions that occurs during startups, shutdowns, and

malfunctions of the affected facility. The nature and

cause of any malfunction (if known), the corrective

action taken or preventative measures adopted.

c) The date and time identifying each period during

which the continuous monitoring system was

inoperative except for zero and span checks and the

nature of the system repairs or adjustments.

d) When no excess emissions have occurred or the

continuous monitoring system(s) have not been

inoperative, repaired, or adjusted, such information

shall be stated in the report.

Semiannually,

by January 31st

and July 31st

each year

EU7 40 CFR 60

Subpart A

Section 60.7(c)

8. The owner or operator of a source subject to 40 CFR 60

which is required to install, calibrate, operate, and maintain a

CEM system shall provide the following information in each

quarterly emission report specified in Env-A 808.11:

a) The information specified in 40 CFR 60.7(c) and any

applicable subpart of 40 CFR 60;

b) The daily averages of gaseous CEM measurements and

calculated emission rates; and

c) The information required in Env-A 808.13(a)(5)

through (9).

Within 30 days

of the end of

each calendar

quarter

EU7 Env-A 808.11,

808.12(a)-(c)

(eff. 10-31-02)

& Temporary

Permit

FP-T-0110

9. Annually, on or before April 15th

of the following year,

submit for each calendar month of the calendar year the

consecutive 12 month NOx, SO2, PM10, VOC, CO, and

H2SO4 mist emissions totals combined from EU1 through

EU10.

Annually, by

April 15th

the

following year

EU1-EU10 Env-A 910 &

Temporary

Permit

FP-T-0110

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Table 7 – Applicable Reporting Requirements

Item

# Reporting Requirements

Frequency of

Reporting

Applicable

Emission

Unit

Regulatory

Citation

10. Semi-annual Monitoring, Testing, and Permit Deviations

Summary Report

The owner or operator shall submit a summary report of

Items #9 and 11 in Table 6, and permit deviations every 6

months. All instances of deviations from Permit

requirements must be clearly identified in such reports. A

responsible official must certify all reports consistent with

Section XXI.B. of this Permit.

Semi-annually

by July 31st and

January 31st of

each calendar

year.

Facility Wide 40 CFR

70.6(a)(3)(iii)(A)

11. Payment of Emission Based Fees

Annual payment of emission based fees shall be conducted in

accordance with Section XXIII of this Permit. The owner or

operator of a stationary source, an area source, or device

having actual emissions of 1,000 tons or less shall pay to the

department the annual emission-based fee no later than April

15th each subsequent year for emissions from the previous

calendar year.

Annually (no

later than April

15th

of the

following year)

Facility Wide

Env-A 705.04

(eff. 6-26-04) &

Temporary

Permit

FP-T-0110

12. Annual Emissions Report

The owner or operator shall submit an annual emissions

report on or before April 15th of the following year

including:

a) The actual calendar year emissions of the stationary

source, area source or device and the methods used in

calculating such emissions in accordance with Env-A

705.02, Determination of Actual Emissions for Use in

Calculating Emission-based Fees; and

b) For combustion devices, all information in accordance

with Env-A 903.03, General Record keeping

Requirements for Combustion Devices.

Annually (no

later than April

15th

of the

following year)

Facility Wide Env-A 907.01

(eff. 4-23-99) &

Temporary

Permit

FP-T-0110

13. Annual Compliance Certification

Annual compliance certification shall be submitted in

accordance with Section XXI of this Permit.

Annually (no

later than April

15th

of the

following year)

Facility Wide 40 CFR

70.6(c)(1)

IX. Requirements Currently Not Applicable:

The Permittee did not identify any requirements which are not applicable to the facility.

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University of New Hampshire

General Title V Operating Permit Conditions

X. Issuance of a Title V Operating Permit

A. This Permit is issued in accordance with the provisions of Env-A 609. In accordance with 40

CFR 70.6(a)(2), this Permit shall expire on the date specified on the cover page of this Permit,

which shall not be later than the date five (5) years after issuance of this Permit.

B. Permit expiration terminates the Permittee's right to operate the Permittee's emission units,

control equipment or associated equipment covered by this permit, unless a timely and complete

renewal application is submitted at least 6 months before the expiration date.

XI. Title V Operating Permit Renewal Procedures

Pursuant to Env-A 609.07(b), an application for renewal of this Permit shall be considered timely if it is

submitted to the Director at least six months prior to the designated expiration date of this Permit.

XII. Application Shield

Pursuant to Env-A 609.08, if an applicant submits a timely and complete application for the issuance or

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the

Director takes final action on the application.

XIII. Permit Shield

A. Pursuant to Env-A 609.09(a), a permit shield shall provide that:

1. For any applicable requirement or any state requirement found in the New Hampshire Rules

Governing the Control of Air Pollution specifically included in this Permit, compliance with

the conditions of this Permit shall be deemed compliance with said applicable requirement or

said state requirement as of the date of permit issuance; and

2. The Permittee need not comply with any applicable requirement or state requirement found

in the New Hampshire Rules Governing the Control of Air Pollution and specifically

identified in Section IX of this Title V Operating Permit as not applicable to the stationary

source or area source.

B. The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions

incorporated into this Permit in accordance with the provisions of Env-A 609.09(b). It shall not

apply to certain conditions as specified in Env-A 609.09(c) that may be incorporated into this

Permit following permit issuance by DES.

C. If a Title V Operating Permit and amendments thereto issued by the DES does not expressly

include or exclude an applicable requirement or a state requirement found in the New Hampshire

Rules Governing the Control of Air Pollution, that applicable requirement or state requirement

shall not be covered by the permit shield and the Permittee shall comply with the provisions of

said requirement to the extent that it applies to the Permittee.

D. If the DES determines that this Title V Operating Permit was issued based upon inaccurate or

incomplete information provided by the applicant or Permittee, any permit shield provisions in

said Title V Operating Permit shall be void as to the portions of said Title V Operating Permit

which are affected, directly or indirectly, by the inaccurate or incomplete information.

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University of New Hampshire

E. Pursuant to Env-A 609.09(f), nothing contained in Section XIII of this Permit shall alter or affect

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.19 or to

exercise its summary abatement authority.

F. Pursuant to Env-A 609.09(g), nothing contained in this section or in any title V operating permit

issued by the DES shall alter or affect the following:

1. The ability of the DES to order abatement requiring immediate compliance with applicable

requirements upon finding that there is an imminent and substantial endangerment to public

health, welfare, or the environment;

2. The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125-

C:15,II;

3. The provisions of section 303 of the CAA regarding emergency orders including the

authority of the EPA Administrator under that section;

4. The liability of an owner or operator of a source for any violation of applicable requirements

prior to or at the time of permit issuance;

5. The applicable requirements of the acid rain program, consistent with section 408(a) of the

CAA;

6. The ability of the DES or the EPA Administrator to obtain information about a stationary

source, area source, or device from the owner or operator pursuant to section 114 of the

CAA; or

7. The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a

stationary source, area source, or device.

XIV. Reopening for Cause

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances

contained in Env-A 609.19(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, the

Director shall follow the provisions specified in Env-A 609.19(b) through (g).

XV. Administrative Permit Amendments

A. Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for

an administrative permit amendment as defined in Env-A 100 immediately upon submittal of the

request.

B. Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative

permit amendment in accordance with the provisions of Env-A 612.01(b) and (c).

XVI. Operational Flexibility

A. Pursuant to Env-A 612.02, the Permittee subject to and operating under this Title V Operating

Permit may make changes involving trading of emissions, off-permit changes, and section

502(b)(10) changes at the permitted stationary source or area source without filing a Title V

Operating Permit application for and obtaining an amended Title V Operating Permit, provided

that all of the following conditions are met, as well as conditions specified in Section XVI. B

through E of this permit, as applicable. At this point, DES has not included any permit terms

authorizing emissions trading in this permit.

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University of New Hampshire

1. The change is not a modification under any provision of Title I of the CAA;

2. The change does not cause emissions to exceed the emissions allowable under the Title V

operating permit, whether expressed therein as a rate of emissions or in terms of total

emissions;

3. The owner or operator has obtained any temporary permit required by Env-A 600;

4. The owner or operator has provided written notification to the director and administrator of

the proposed change and such written notification includes:

a. The date on which each proposed change will occur;

b. A description of each such change;

c. Any change in emissions that will result;

d. A request that the operational flexibility procedures be used; and

e. The signature of the responsible official, consistent with Env-A 605.04(b);

5. The change does not exceed any emissions limitations established under any of the

following:

a. The New Hampshire Code of Administrative Rules, Env-A 100-3800;

b. The CAA; or

c. This Title V Operating Permit; and

6. The Permittee, DES, and EPA have attached each written notice required above to their copy

of this Title V Operating Permit.

B. For changes involving the trading of emissions, the Permittee must also meet the following

conditions:

1. The Title V Operating Permit issued to the stationary source or area source already contains

terms and conditions including all terms and conditions which determine compliance

required under 40 CFR 70.6(a) and (c) and which allow for the trading of emissions increases

and decreases at the permitted stationary source or area source solely for the purpose of

complying with a federally-enforceable emissions cap that is established in the permit

independent of otherwise applicable requirements;

2. The owner or operator has included in the application for the Title V Operating Permit

proposed replicable procedures and proposed permit terms which ensure that the emissions

trades are quantifiable and federally enforceable for changes to the Title V Operating Permit

which qualify under a federally- enforceable emissions cap that is established in the Title V

Operating Permit independent of the otherwise applicable requirements;

3. The Director has not included in the emissions trading provision any devices for which

emissions are not quantifiable or for which there are no replicable procedures to enforce

emissions trades; and

4. The written notification required above is made at least 7 days prior to the proposed change

and includes a statement as to how any change in emissions will comply with the terms and

conditions of the Title V Operating Permit.

C. For off-permit changes, the Permittee must also meet the following conditions:

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University of New Hampshire

1. Each off-permit change meets all applicable requirements and does not violate any existing

permit term or condition;

2. The written notification required above is made contemporaneously with each off-permit

change, except for changes that qualify as insignificant under the provisions of Env-A

609.04;

3. The change is not subject to any requirements under Title IV of the CAA and the change is

not a Title I modification;

4. The Permittee keeps a record describing the changes made at the source which result in

emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise

regulated under this Permit, and the emissions resulting from those changes; and

5. The written notification required above includes a list of the pollutants emitted and any

applicable requirement that would apply as a result of the change.

D. For section 502(b)(10) changes, the Permittee must also meet the following conditions:

1. The written notification required above is made at least 7 days prior to the proposed change;

and

2. The written notification required above includes any permit term or condition that is no

longer applicable as a result of the change.

E. Pursuant to Env-A 612.02(f), the off-permit change and section 502(b)(10) change shall not

qualify for the permit shield under Env-A 609.09.

XVII. Minor Modifications

A. Prior to implementing a minor permit modification, the Permittee shall submit a written request

to the Director in accordance with the requirements of Env-A 612.05(b).

B. The Director shall take final action on the minor permit amendment request in accordance with

the provisions of Env-A 612.05(c) through (g).

C. Pursuant to Env-A 612.05(h), the permit shield specified in Env-A 609.09 shall not apply to

minor permit amendments under Section XVII. of this Permit.

D. Pursuant to Env-A 612.05(a), the Permittee shall be subject to the provisions of RSA 125-C:15 if

the change is made prior to the filing with the Director of a request for a minor permit

amendment.

XVIII. Significant Permit Modifications

A. Pursuant to Env-A 612.06, a change at the facility shall qualify as a significant permit

amendment if it meets the criteria specified in Env-A 612.06(a)(1) through (5).

B. Prior to implementing the significant permit amendment, the Permittee shall submit a written

request to the Director which includes all the information as referenced in Env-A 612.06(b) and

(c) and shall be issued an amended Title V Operating Permit from the DES. The Permittee shall

be subject to the provisions of RSA 125-C:15 if a request for a significant permit amendment is

not filed with the Director and/or the change is made prior to the issuance of an amended Title V

Operating Permit.

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University of New Hampshire

C. The Director shall take final action on the significant permit amendment in accordance with the

Procedures specified in Env-A 612.06(e) and (f).

XIX. Title V Operating Permit Suspension, Revocation or Nullification

A. Pursuant to RSA 125-C:13, the Director may suspend or revoke any final permit issued

hereunder if, following a hearing, the Director determines that:

1. The Permittee has committed a violation of any applicable statute or state requirement found

in the New Hampshire Rules Governing the Control of Air Pollution, order or permit

condition in force and applicable to it; or

2. The emissions from any device to which this Permit applies, alone or in conjunction with

other sources of the same pollutants, presents an immediate danger to the public health.

B. The Director shall nullify any Permit if, following a hearing in accordance with RSA 541-A:30,

II, a finding is made that the Permit was issued in whole or in part based upon any information

proven to be intentionally false or misleading.

XX. Inspection and Entry

EPA and DES personnel shall be granted access to the facility covered by this Permit, in accordance with

RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted site; investigating a complaint;

and assuring compliance with any applicable requirement or state requirement found in the New Hampshire

Rules Governing the Control of Air Pollution and/or conditions of any Permit issued pursuant to Chapter

Env-A 600.

XXI. Certifications

A. Compliance Certification Report

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify for the previous

calendar year that the facility is in compliance with the requirements of this permit. The report

shall be submitted annually, no later than April 15th of the following year. The report shall be

submitted to the DES and to the U.S. Environmental Protection Agency – Region I. The report

shall be submitted in compliance with the submission requirements below.

In accordance with 40 CFR 70.6(c)(5), the report shall describe:

1. The terms and conditions of the Permit that are the basis of the certification;

2. The current compliance status of the source with respect to the terms and conditions of this

Permit, and whether compliance was continuous or intermittent during the reporting period;

3. The methods used for determining compliance, including a description of the monitoring,

record keeping, and reporting requirements and test methods; and

4. Any additional information required by the DES to determine the compliance status of the

source.

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University of New Hampshire

B. Certification of Accuracy Statement

All documents submitted to the DES shall contain a certification by the responsible official of truth,

accuracy, and completeness. Such certification shall be in accordance with the requirements of 40

CFR 70.5(d) and contain the following language:

"I am authorized to make this submission on behalf of the facility for

which the submission is made. Based on information and belief formed

after reasonable inquiry, I certify that the statements and information in

the enclosed documents are to the best of my knowledge and belief true,

accurate and complete. I am aware that there are significant penalties for

submitting false statements and information or omitting required

statements and information, including the possibility of fine or

imprisonment."

All reports submitted to DES (except those submitted as emission based fees as outlined in Section

XXIII of this Permit) shall be submitted to the following address:

New Hampshire Department of Environmental Services

Air Resources Division

29 Hazen Drive

P.O. Box 95

Concord, NH 03302-0095

ATTN: Section Supervisor, Compliance Bureau

All reports submitted to EPA shall be submitted to the following address:

Office of Environmental Stewardship

Director Air Compliance Program

United States Environmental Protection Agency

1 Congress Street

Suite 1100 (SEA)

Boston, MA 02114-2023

ATTN: Air Compliance Clerk

XXII. Enforcement

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. Section

7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for denial of an

operating permit renewal application by the DES and/or EPA. Noncompliance may also be grounds for

assessment of administrative, civil or criminal penalties in accordance with RSA 125-C:15 and/or the Clean

Air Act. This Permit does not relieve the Permittee from the obligation to comply with any other provisions

of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the Clean Air Act, or

to obtain any other necessary authorizations from other governmental agencies, or to comply with all other

applicable Federal, State, or Local rules and regulations, not addressed in this Permit.

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University of New Hampshire

In accordance with 40 CFR 70.6 (a)(6)(ii), a Permittee shall not claim as a defense in an enforcement action

that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance

with the conditions of this Permit.

XXIII. Emission-Based Fee Requirements

A. The Permittee shall pay an emission-based fee annually for this facility as calculated each

calendar year pursuant to Env-A 705.03.

B. The Permittee shall determine the total actual annual emissions from the facility to be included in

the emission-based multiplier specified in Env-A 705.03(a) for each calendar year in accordance

with the methods specified in Env-A 616.

C. The Permittee shall calculate the annual emission-based fee for each calendar year in accordance

with the procedures specified in Env-A 705.03 and the following equation:

Where:

FEE = The annual emission-based fee for each calendar year as specified in Env-A 705.

E = The calculation of total annual emissions as specified in Env-A 705.02 and the

provisions specified in Env-A 705.03(a).

DPT = The dollar per ton fee the DES has specified in Env-A 705.03(b).

CPIm= The Consumer Price Index Multiplier as calculated in Env-A 705.03(c).

ISF = The Inventory Stabilization Factor as specified in Env-A 705.03(d).

D. The Permittee shall contact the DES each calendar year for the value of the Inventory

Stabilization Factor.

E. The Permittee shall contact the DES each calendar year for the value of the Consumer Price

Index Multiplier.

F. The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the

calculations referenced in Sections XXIII.B. and C of this Permit for each calendar year no later

than April 15 each subsequent year for the emissions from the previous calendar year. The

emission-based fee and summary of the calculations shall be submitted to the following address:

New Hampshire Department of Environmental Services

Air Resources Division

P.O. Box 95

Concord, NH 03302-0095

ATTN.: Emissions Inventory

G. The DES shall notify the Permittee of any under payments or over payments of the annual

emission-based fee in accordance with Env-A 705.05.

ISF* CPIm* DPT* E = FEE

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University of New Hampshire

XXIV. Duty To Provide Information

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish,

within a reasonable time, any information necessary for determining whether cause exists for modifying,

revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon

request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain by

this Permit. The Permittee may make a claim of confidentiality as to any information submitted pursuant to

this condition in accordance with Env-A 103 at the time such information is submitted to DES. DES shall

evaluate such requests in accordance with the provisions of Env-A 103.

XXV. Property Rights

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any

exclusive privilege.

XXVI. Severability Clause

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the

application of such provision to other circumstances, and the remainder of this Permit, shall not be affected

thereby.

XXVII. Emergency Conditions

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for

noncompliance with technology based17 emission limitations specified in this Permit as a result of an

emergency18. In order to use emergency as an affirmative defense to an action brought for noncompliance,

the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating

logs, or other relevant evidence that:

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency;

B. The permitted facility was at the time being properly operated;

C. During the period of the emergency, the Permittee took all reasonable steps as expeditiously as

possible, to minimize levels of emissions that exceeded the emissions standards, or other

requirements in this Permit; and

17 Technology based emission limits are those established on the basis of emission reductions achievable with various

control measures or process changes (e.g., a new source performance standard) rather than those established to attain

health based air quality standards.

18

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control

of the source, including acts of God, which situation would require immediate corrective action to restore normal

operation, and that causes the source to exceed a technology based limitation under the permit, due to unavoidable

increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused

by improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or

decision to keep operating despite knowledge of any of these things.

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University of New Hampshire

D. The Permittee submitted notice of the emergency to the DES within two (2) business days of the

time when emission limitations were exceeded due to the emergency. This notice must contain a

description of the emergency, any steps taken to mitigate emission, and corrective actions taken.

XXVIII. Permit Deviation

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of

deviations from Permit requirements, by telephone, fax, or e-mail ([email protected]) within 24

hours of discovery of such deviation. This report shall include the deviation itself, including those

attributable to upset conditions as defined in this Permit, the probable cause of such deviations, and any

corrective actions or preventative measures taken.

Within 10 days of discovery of the permit deviation, the Permittee shall submit a written report including

the above information as well as the following: preventive measures taken to prevent future occurrences;

date and time the permitted device returned to normal operation; specific device, process or air pollution

control equipment that contributed to the permit deviation; type and quantity of excess emissions emitted to

the atmosphere due to permit deviation; and an explanation of the calculation or estimation used to quantify

excess emissions.

Said Permit deviation shall also be submitted in writing to the DES in the semi-annual summary report of

monitoring and testing requirements due July 31st and January 31st of each calendar year. Deviations are

instances where any Permit condition is violated and has not already been reported as an emergency

pursuant to Section XXVII. of this Permit.

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance.

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University of New Hampshire

ATTACHMENT A

LIST OF ALL EMERGENCY GENERATORS ABOVE 150,000 Btu/hr

Emission

Unit ID

Description

& Location

Manufacturer Model Serial # kW Fuel Firing

Rate

(gal/hr or

cf/hr)

Heat

Input

(MMBtu/

hr)

Date

Installed

EG1 Central

Heating Plant

Caterpillar 3306/SR4 45BH1535 155 Diesel 12.3 1.7 Pre 1999

EG2 Morse

Building

Caterpillar 3406/SR4 2WB03136 250 Diesel 19 2.6 Pre 1999

EG3 New England

Center

Caterpillar 3306/SR4 85Z04098 200 Diesel 15.8 2.2 Pre 1999

EG4 Water Supply Allis/Chalmers 25000 1-

7451-69053

25-03545 200 Diesel 15 2.1 Pre 1999

EG5 Gables

Building

Caterpillar 3268A AD201080SM

L

250 Nat Gas 3200 3.2 Pre 1999

EG6 Whittemore

Center

Caterpillar 3306 2TM00105 250 Diesel 19.4 2.7 Pre 1999

EG7 Rudman

Building

(Biosciences)

Caterpillar 3412/SR4 81Z16491 600 Diesel 46.1 6.3 Pre 1999

EG8 Black Start

Emergency

Generator at

CT Plant

Caterpillar 3412/SR4B BLG02735 750 Diesel 54.8 7.5 2004

EG9 Data Center Caterpillar 3306 7YR02974 250 Diesel 19.1 2.6 Pre 2006

EG10 ETB Unknown Unknown 8TF01429 150 Nat Gas 734 0.73 Pre 2006 EG11 Mills

Building

Caterpillar 3406 CBP00183 240 Nat Gas 2700 2.7 Pre 2006

EG12 Holloway

Building

Cummins GTA855G3 Unknown 250 Nat Gas 1400 1.4 Pre 2006

EG13 Dispatch EG Generac 20A00611-S 2055173 20 Diesel 2 0.27 Pre 2006 EG14 Huddleston

Building

Kohler 30R82

91427A29

358156 30 Nat Gas 500 0.5 Pre 2006

EG15 Dimond

Library

Olympian 97 A02882-

S

2035177 200 Diesel 15.6 2.1 Pre 2006

EG16 Parson 1 Olympian G45F1 E5206E/001 45 Nat Gas 585 0.59 Pre 2006 EG17 PMS

Building

Olympian G50F3 Unknown 45 Nat Gas 585 0.59 Pre 2006

EG18 Stoke

Building

Olympian G15U1 D11731/001 15 Nat Gas 255 0.26 Pre 2006

EG19 Christenson

Building

Onan 45 EM-

4R/7605A

98059653 45 Nat Gas 585 0.59 Pre 2006

EG20 Coastal

Marine

Building

Onan Unknown C880107523 30 Diesel 2.6 0.36 Pre 2006

EG21 Field House

Building

Onan 60.0DGCB-

130547A

L870951296 60 Diesel 4.7 0.64 Pre 2006

EG22 Fire

Department

Olympian Unknown Unknown 25 Nat Gas 450 0.45 Pre 2006

EG23 Horton

Building

Onan 15RJC-

4XR8/6335

R

Unknown 15 Nat Gas 255 0.26 Pre 2006

EG24 Jackson

Laboratory

Onan 76C90X8LI Unknown 25 Diesel 2.5 0.34 Pre 2006

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University of New Hampshire

Emission

Unit ID

Description

& Location

Manufacturer Model Serial # kW Fuel Firing

Rate

(gal/hr or

cf/hr)

Heat

Input

(MMBtu/

hr)

Date

Installed

EG25 Kendall

Building

Onan 30EK-

4RB8/3305

A

170158180 30 Nat Gas 600 0.6 Pre 2006

EG26 McConnell

Building

Onan 30EK-

4XRB/6392

8

1068069796 30 Nat Gas 600 0.6 Pre 2006

EG27 Mini Dorm

Building

Onan 30 ODEH-

15R/2072G

575953909 30 Diesel 2.6 0.36 Pre 2006

EG28 Parson 2

Building

Onan 45EM-

4XR8/769A

20912-C20KR 45 Nat Gas 585 0.59 Pre 2006

EG29 Philbrook

Building

Onan 85.0KR-

15R/926IN

7702197785 85 Nat Gas 1400 1.4 Pre 2006

EG30 Telecom

Building

Onan 1150WA-

115R/2837O

L

G850770776 115 Nat Gas 1500 1.5 Pre 2006

EG31 Williamson

Building

Onan 45.0ER-

15R/9928C

127270312 45 Nat Gas 585 0.59 Pre 2006

EG32 Health

Service

Building

Superior 45R431 1187650 45 Nat Gas 600 0.6 Pre 2006

EG33 Randall Hall Caterpillar G80F3 05QS48626 63.

5

Nat Gas 894 0.912 2007

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University of New Hampshire

ATTACHMENT B

List of All Emissions Units Included in the Facility Wide Criteria Pollutant Emissions Caps Emission Unit

ID

Description & Location Maximum Heat Input Rate

(MMBtu/hr) & Fuels

EU1 Boiler 1 at the Central Heating Plant 47.3 (No. 6 FO or Nat Gas)

EU2 Boiler 2 at the Central Heating Plant 47.3 (No. 6 FO or Nat Gas)

EU3 Boiler 3 at the Central Heating Plant 47.3 (No. 6 FO or Nat Gas)

EU4 Boiler 4 at the Central Heating Plant 47.3 (No. 6 FO or Nat Gas)

EU5 Boiler 5 at the Central Heating Plant 16.7 (No. 6 FO or Nat Gas)

EU6 Boiler 6 at the New England Center 12.6 (No. 2 FO or Nat Gas)

EU7 Combustion Turbine at the new Cooling, Heating, and Power Plant 104.8 (No. 2 FO) &

106.0 (Nat Gas)

EU8 Heat Recovery Steam Generator with Duct Burner at the new Cooling, Heating,

and Power Plant

66.3 (Nat Gas)

EU9 Black Start Emergency Generator 7.5 (Diesel)

EG1 Central Heating Plant Emergency Generator 1.7 (Diesel)

EG2 Morse Building Emergency Generator 2.6 (Diesel)

EG3 New England Center Emergency Generator 2.2(Diesel)

EG4 Water Supply Emergency Generator 2.1 (Diesel)

EG5 Gables Building Emergency Generator 3.2 (Nat Gas)

EG6 Whittemore Center Emergency Generator 2.7 (Diesel)

EG7 Rudman Building (Biosciences) Emergency Generator 6.3 (Diesel)

Holloway Commons Dining Hall Emergency Generator 2.88 (Nat Gas)

Mills Hall Emergency Generator 2.80 (Nat Gas)

Greg Hall (Environmental Technology Building) Emergency Generator 1.93 (LPG)

Central Heating Plant Emergency Generator 0.25 (Diesel)

PAMS Building Emergency Generator 0.67 (Propane)

Craft Cottage Boiler/Heater 0.20 (Nat Gas)

Schofield House Boiler/Heater 0.20 (Nat Gas)

Verret House Boiler/Heater 0.20 (Nat Gas) Stoke Building Boiler/Heater 0.20 (Nat Gas) Lockinvar1 Building Boiler/Heater 0.20 (Nat Gas) Lockinvar2 Building Boiler/Heater 0.20 (Nat Gas) Philbrook1 Building Boiler/Heater 0.20 (Nat Gas) Philbrook2 Building Boiler/Heater 0.20 (Nat Gas) Barton/Cote Buildings Boiler/Heater 0.20 (Nat Gas) Greg Hall (Environmental Technology Building) Boiler/Heater #1 3.57 (Diesel)

Greg Hall (Environmental Technology Building) Boiler/Heater #2 3.57 (Diesel)

Greg Hall (Environmental Technology Building) Boiler/Heater #3 3.57 (Diesel)